The Royce Funds
745 Fifth Avenue
New York, NY 10151
212-508-4500
800-221-4268
e-mail: funds@royceinvest.com website: www.royceinvest.com
May 14, 2020
VIA EDGAR CORRESPONDENCE
Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E. Washington, D.C. 20549
Atten: Ms. Cindy Chang
Re: Annual Report to Stockholders for the year ended December 31, 2019 for each of Royce Micro-Cap Trust, Inc. (File No. 811-08030), Royce Value Trust, Inc.
(File No. 811-04875), and Royce Global Value Trust, Inc. (File No. 811-22532)
Dear Ms. Chang:
At your request, and as we discussed over the telephone, in connection with the staff’s comments relating to each of the above-referenced Annual Reports to Stockholders, set forth below are the staff’s comments and the Funds’ responses.
Royce Micro-Cap Trust, Inc.
Royce Value Trust, Inc.
Royce Global Value Trust, Inc,
Comment: Please amend each Funds’ Form N-CEN to attach each Funds’ internal control report from the Funds’ Independent Accountants for the year ended December 31, 2019.
Response: On April 17, 2020, each Fund filed a Form N-CEN/A for the year ended December 31, 2019 per your above request.
Comment: Please include disclosure in the Notes to the Financial Statements contained in the Funds’ Annual Reports to Stockholders that sets forth disclosure regarding the maximum amount of borrowing permitted under each Funds’ revolving credit agreement and the conditions under which such line of credit may be withdrawn from each Fund (See Reg-SX 210.5-02.19b).
Response: We will expand the disclosure regarding borrowings per the above request in future N-CSR filings.
Please direct any further communication relating to this filing to John E. Denneen at (212) 508-4578.
Very truly yours,
| /s/ Peter K. Hoglund | /s/ John E. Denneen | |
| Peter K. Hoglund | John E. Denneen | |
| Treasurer | Secretary |
| cc: | Christopher D. Clark Mary Macchia Frank P. Bruno, Esq. |
